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Home My WebLink About10-2577U Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 235922 WELLS FARGO BANK, N.A., SB/M WELLS FARGO HOME MORTGAGE, INC. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 Plaintiff V. RUSSELL E. CLOUSER LISA M. CLOUSER 11 COUNTRYSIDE COURT CAMP HILL, PA 17011-1518 Defendants v r cry! 93 fr6 33 2otio APR za ? z? sa 0 3-yo loo.)- ijy CUM ????INO ItLt?!'v l?. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. 16_ - -S-77 / iffl- CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 235922 NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 235922 I . Plaintiff is WELLS FARGO BANK, N.A., S/B/M WELLS FARGO HOME MORTGAGE, INC. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 2. The name(s) and last known address(es) of the Defendant(s) are: RUSSELL E. CLOUSER LISA M. CLOUSER 11 COUNTRYSIDE COURT CAMP HILL, PA 17011-1518 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 07/07/2003 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to COLUMBIA NATIONAL INCORPORATED which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1824, Page 4882. By Assignment of Mortgage recorded 10/08/2003 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 702, Page 3443. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 08/01/2009 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 235922 6. The following amounts are due on the mortgage: Principal Balance $110,874.28 Interest $4,784.69 07/01/2009 through 04/19/2010 (Per Diem $16.33) Attorney's Fees $650.00 Cumulative Late Charges $0.00 07/07/2003 to 04/19/2010 Costs of Suit and Title Search 550.00 Subtotal $116,858.97 Escrow Credit 147.33 TOTAL $116,711.64 7 Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. File #: 235922 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $116,711.64, together with interest from 04/19/2010 at the rate of $16.33 per diem to the date of judgment, and other costs, fees, and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN & SCHMIEG, LLP By: /[j Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorneys for Plaintiff File k: 235922 LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate, lying and being in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the westerly right-of-way line of Countryside Court, a 50.00 foot wide right-of-way, which said point is more particularly located at the intersection of the westerly right-of-way line of Countryside Court and the dividing line between Lots Nos. 98 and 99 on the Plan of Lots known as 'Countryside, Section (B); thence, from said point of beginning along the dividing line between Lots Nos. 98 and 99, South 81 degrees 16 minutes 00 seconds West, a distance of 118.00 feet to a point on the dividing line between Lots Nos. 97 and 99 on the aforesaid Plan of Lots; thence, from said point along the dividing line between Lots Nos. 97 and 98 and 99, North 08 degrees 44 minutes 00 seconds West, a distance of 85.00 feet to a point on the dividing line between Lots Nos. 99 and 100 on the aforesaid Plan of Lots; thence, from said point along the dividing line between Lots Nos. 99 and 100, North 81 degrees 16 minutes 00 seconds East, a distance of 118.00 feet to a point on the westerly right-of-way line of Countryside Court, South 08 degrees 44 minutes 00 seconds East, a distance of 85.00 feet to a point, the point and place of BEGINNING. BEING Lot No. 99 on the Plan of Lots known as Countryside, Section (B) prepared by Charles W. Junkins, Registered Surveyor, dated August 22, 1978 and recorded in the Office of the Recorder of Deeds of Cumberland County on April 11, 1974 in Plan Book 25, Page 7. HAVING THEREON ERECTED a dwelling house known and numbered as premises 11 Countryside Court, Camp Hill, Pennsylvania. PROPERTY ADDRESS: 11 COUNTRYSIDE COURT, CAMP HILL, PA 17011 BEING Parcel No. 10-19-1596-092. File #: 235922 VERIFICATION The undersigned attorney hereby states that I am the attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to authorities. ey for Plaintiff DATE: \ t File #: 235922 WELLS FARGO BANK. N.A., SB/M WELLS FARGO HOME MORTGAGE, INC., Plaintiff v. RUSSELL E. CLOUSER and LISA M. CLOUSER, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW ?37'1 NO. 10-23~ CIVIL TERM IN RE: PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT BEFORE OLER and EBERT, JJ. ORDER OF COURT AND NOW, this 8~' day of July, 2010, upon consideration of Plaintiff's Motion for Summary Judgment and Brief in Support thereof, and Defendants' failure to file a Response to Plaintiff s Motion and Brief, and Defendants' failure to appear for oral argument held on July 7, 2010, the court determines that Plaintiff is entitled to Summary Judgment as a matter of law, and it is hereby ordered and directed that an in rem judgment is entered in favor of Plaintiff and against Defendants, Russell E. Clouser and Lisa M. Clouser, for $116,711.64 plus interest from April 19, 2010, at the rate of $16.33 per diem to the date of judgment and interest at the legal rate thereafter, plus other costs and charges collectible under the mortgage for foreclosure and sale of the mortgaged property. BY THE COURT, ~ ~ -- - 7 ~ ~:> :. p ~. r ^7 ; ~4 t / ~ ~ f~, ~ ~, ~ 4 ~ 1"i°I i~ .. ~ ~.` ~ J{ esley Ole -fir. J. ~ - `S ~ = - ` - iii ~ - ~ ~ T3 ~; ~y ..~ ~.a7 `"~ ~seph P. Schalk, Esq. 126 Locust Street Harrisburg, Pa 17101 Attorney for Plaintiff /Russell E. Clouser and Lisa M. Clouser 11 Countryside Court Camp Hill, PA 17011-1518 Defendants, pro Se ~o ~ ~ ~~ 7~~~ro ~~ PLAINTIFF WELLS FARGO BANK, N.A., S/B/M WELLS FARGO HOME MORTGAGE, INC. DEFENDANT RUSSELL E. CLOUSER LISA M. CLOUSER SERVE LISA M. CLOUSER AT: 11 COUNTRYSIDE COURT CAMP HILL, PA 17011-1518 PHS # 235922 SERVICE TEAM/ kxc COURT NO.: 10-2577-CIVIL TERM TYPE OF ACTION XX Notice of Sheriff's Sale SALE DATE: 12/0812010 SERVED Served and made known to LISA M. CLOUSER , Defendant on the %4%day of &05'5 .20 O , at S 4t , o'clock f. M., at #'&p1*YWj* QE, eftf 94" Pk, in the manner descnbed below: _ Defendant personally served. Adult family member ith whom Defendant(s) reside(s). Relationship is S (?Nfl _ Adult in charge of Defendant's residence who refused to give name or relationship. - Manager/Clerk of place of lodging in which Defendant(s) reside(s). - Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. _ Other: Description: Age 4ae Height bIb r Weight 110 Race W Sex _ M Other I, /?Jp'A Af ( F? a competent adult, being duly sworn according to law, depose and state that I personally handed a true and cogect copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed befo me this 304 day I Y CUl rY of lk , 201 N r By: b?' RS G1 f NOT SERVED i )Y ; : ^ V 1K4.? NlA:.CH 7, 2J i 3 On the d' 20_, at _ _o'clock_. M., Defendant NOT FOUNDcause V c t _ Does Not Exist _ Moved Does Not Reside (Not Vacant) N e n at at Service Refused Other: Sworn to and subscribed before me this day of By: Notary: AFFIDAVIT OF SEPVICE (.FHLMC) CUMBERLAND COUNTY ATTORNEY FOR PLAINTIFF Lavrravee T. Phelsm Esq.. hi No. 32227 Francis S. Milk-, Esq, Id. No. 62695 Daniel G. Sehudeg, Esq., Id. No. 62205 Michele M. Bradford, Fsq., Id. No. 69849 . Judith T. Ransom, Esq., Id. N. 58745 V 4 ShMal R Sheh_Jard, Esq. Id. Na 81760 I e C E.7., Jenine R. Davey. Esq., Id. No. 87Wn A Lauren R. Tabus, Esq., Id. N. 93337 ' Vtvek Srivastava, Esq Id. No. 202331 m ` ... Jay S. Jones, Esq., Id. No. 86657 , 1,-? " . •-7.. Petcr J. Mukahy, Fay, ld. No.61791 " - :,. t .•, 21..1_a --"` Aodm L. Splvach. Fsq., Id" No. 84439 - Jaime McGuinness, Esq., Id. No. 90134 Chrisovalantc P. Micro, Fsq., Id. No. 94620 . '> ?-.- t Jushuo L Goldmr, Esq, Id. No. 205047 . .cis" . • ?-d Courleoay R. Dunn, Esq., Id. No. 206779 °-•-{ 1~'"°?, "".?. Andrew C Braroblett, Fsn., ld. No. 200375 (hn Penn CeNCrtl $obu Station 1617 John F. Kennedy Blvd, Suite 1400 ' , Phihdelphia, PA 19103-1814 (215) 5657000 PLAINTIFF WELLS FARGO BANK, N.A., S/B/M WELLS FARGO HOME MORTGAGE, INC. DEFENDANT RUSSELL E. CLOUSER LISA M. CLOUSER SERVE RUSSELL E. CLOUSER AT: 11 COUNTRYSIDE COURT CAMP HILL, PA 17011-1518 PHS # 235922 SERVICE TEAM/ kxc COURT NO.: 10-2577-CIVIL TERM TYPE OF ACTION XX Notice of Sheriff's Sale SALE DATE: 12/08!2010 SERVED Served and made known to RUSSELL E. CLOU ER , Defendant on the day of lr057 20 10 at :Zk Or (W (hc t, A in the manner described below: L-4 _(1 o clock , . M., at f 1 uMrR.? _ Defendant personally served. - Adult family member with whom Defendant(s) reside(s). Relationship is _ Adult in charge of Defendant's residence who refused to give name or relationship. _ Manager/Clerk of place of lodging in which Defendant(s) reside(s). _ Agent or person in charge of Defendant's office or usual place of business. _ an officer of said Defendant's company. _ Other: Description: Age 0' Height b'o Weight J q6 Race W Sex * Other I, - 4okki? AAW-L , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed "" - ° - -- before this _30A day y CI, R,fy -_ ..? of 20L "''t hY F'LLuc No ''r 11N AERSEY may. MA kCI! i, 2013 NOT SERVED On the day 20_, at ! o'clock _. M., Defendant NOT FOUND because: cant - Does Not Exist _ Moved Does Not Reside (Not Vacant) _ Na on at at Service Refused Other: Sworn to and subscribed before me this day of By: Notary: AFFIDAVIT OF SERVICE (FHLMC) CUMBERLAND COUNTY ATTORNEY FOR PLAINTIFF Law,erax T. p'bdea. Fsq, ld. Na 3?22T Fwaaeb S. Haanan, Esq, Id. Na 62695 DanieiG. Sdmk& FAQ, Id. Na 62205 Mkink M. findrerd, Esq., Id. No.69849 Jad th T. Romer, Esq., Sit Na SP45 %edal R Shah-Jad, Esq., Id. Na 81768 Ja*w P. Dovey, Esq., Id. No. 87177 !.amen R Tabas, Eat, M. No, 93377 Viva- Sdvmwve, Esq, I6. Ne, 202731 Jay It Jams, Fsq„ K Nm 86657 Mew J. Mekahy, Esq., Id. Na 61791 Andrew L Splvaek, Eaq, Id. Na. NM Jaime WGWmras, Esq.. Id. Na 91137 Cbdso,AWt P. FBakos, Esq., Id. Na 97620 Joshr L GeMw^ Esq., Id. No. 205077 Coawknay IL Dra Psq, Id. Na 206719 Andrew C. BnwMett, Fsq, hL Na 208375 One ? J Pma Corder et Subuhen S7alm amedy llhd, Selle 1400 Pb%nd,V", PA 191031814 (215)563.7000 „'"? ?-,• ti`s} j rT,; ?4 10 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., S/13/M WELLS CUMBERLAND COUNTY FARGO HOME MORTGAGE, INC. Plaintiff, COURT OF COMMON PLEAS CIVIL DIVISION RUSSELL E. CLOUSER No.: 10-2577-CIVIL TERM LISA M. CLOUSER Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attacb,Ohereto Exhibit "A". ;' ;-? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan. Esq., Id. No. 62695 ? Daniel G. Sclimieg, Esq., Id. No. 62205 ? Michele M. Bradford; Esq., Id. No. 69849 [? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jam, Esq., Id. No. 81760 Jenine R. Davey, Esq,, Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id, No. 84439 Jaime McGuinness, Esq., Id. No. 90134 [] Chrisovalante P. Fliakos, Esq.; Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 - ? Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Attorney for Plaintiff O IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the.nlaintiff at the Sheriffs Sale. The sale must be postponed or stayed' in the event that a representative of the plaintiff is not present at the sale. PHS 9 235922 WELLS FARGO BANK, N.A., S/B/M[ WELLS FARGO COURT OF COMMON PLEAS HOME MORTGAGE, INC. Plaintiff CIVIL DIVISION V. NO. 10-2577-CIVIL TERM RUSSELL E. CLOUSER CUMBERLAND' COUNTY LISA M. CLOUSER Defendant(s) PHS # 235922 AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 `WELLS FARGO BANK, N.A., S/B/M WELLS FARGO HOME MORTGAGE, INC., Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 11 COUNTRYSIDE COURT, CAMP HILL, PA 17011-1518. 1. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) RUSSELL E. CLOUSER LISA M. CLOUSER 2. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE 11 COUNTRYSIDE COURT CAMP HILL, PA 17011-1518 I1 COUNTRYSIDE COURT CAMP HILL, PA 17011-1518 Address (if address cannot be reasonably ascertained, please so indicate) 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) Bank of America, N.A. (USA) 4161 Piedmont Parkway Greensboro, NC 27410 Bank of America, N.A. (USA) 10 East High Street C/o: Christopher E. Rice, Esquire Carlisle, PA 17013 Citibank (South Dakota),N.A. 701 East 60"' Street North Sioux Falls, SD 57104-0432 Citibank (South Dakota), N.A. C/o: Neil Burton; Esquire Commerce Bank,', N.A. C./o: Eric M. Berman, Esquire Commerce Bank,'?N.A. C/o: Robert M. Kline, Esquire Bank of America, N.A. (USA) c/oBurton Neil; ,Esq. COMMERCE BANK, N.A. 1060 Andrew Drive; Suite 170 West Chester, PA 19380 500 West Main Street Babylon, NY 11702 500 North Gulph Road; #350 King of Prussia, P, 19406-2616 BURTON NEIL & ASSOCS PC 1060 ANDREW DR STE 170 WEST CHESTER, PA 19380 3930 S. 147th St. Ste. 200 Omaha, NE 68144 COMMERCE BANK, N.A. P.O. Box 413658 Kansas City, MO 64141-3658 COMMERCE BANK, N.A. 922 Walnut, Suite 1100, MS: TBIl-cm3 Kansas City, MO 64106 !COMMERCE BANK, N.A. 1701 Route 70 East c/o TD Bank Cherry Hill, NJ 08003 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom ' the plaintiff has knowledge who has any interest in the property which may be affected bythe sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT 11 COUNTRYSIDE COURT CAMP DILL, PA 17011-1518 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle, PA 17013 Commonwealth of Pennsylvania P.O. Box 2675 Department of Welfare Harrisburg, PA 17105 Internal Revenue Service Advisory 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 U.S. Department of Justice Federal Building, P.O. Box 11754 U.S. Attorney for the Middle District of PA 228 Walnut Street Harrisburg, PA 17108 1 ¦ s I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief: I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsifi6a9 to authorities. tt ?? Attorney for? 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N M '?T to w cs Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney For Plaintiff C) c ? - l = r,nw L-. rn-- WELLS FARGO BANK, N.A., S/B/M WELLS FARGO Court of Common ? HOME MORTGAGE, INC. cn v o C) Plaintiff Civil Division cd s° vs CUMBERLAND Cou -4m RUSSELL E. CLOUSER No. 10-2577-CIVIL TERM LISA M. CLOUSER , Defendant TO THE PROTHONOTARY: PRAECIPE Please withdraw the complaint a nd mark the action discontinued and ended without prejudice. Date: _1 _, ao- tk PH HALLINAN & SCHMIEG, LLP .. By: ? } Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 PHS# 235922 Attorneys for Plaintiff .A Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY L4 ??? flt 4iullb,",414 F c-ERIFF Wells Fargo Bank, NA vs. Russell E. Clouser (et al.) SHERIFF'S RETURN OF SERVICE Case Number 2010-2577 10/08/2010 12:49 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on 10-08-10 at 1240 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Russell E. & Lisa M. Clouser, located at, 11 Countryside Court, Camp Hill, Cumberland County, Pennsylvania according to law. 10/08/2010 12:49 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on 10-08-10 at 1240 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Russell E. Clouser, by making known unto, Russell E. Clouser, personally, at, 11 Countryside Court, Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 10/08/2010 12:49 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on 10-08-10 at 1240 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Lisa M. Clouser, by making known unto, Russell E. Clouser, husband of defendant, at, 11 Countryside Court, Camp Hill, Cumberland County. Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 12/02/2010 As directed by Daniel Schmieg, Attorney for the Plaintiff, Sheriffs Sale Continued to 2/2/2011 01/20/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney Schmieg on 1/19/11. SHERIFF COST: $728.75 January 20, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF -? op e,4. Co. _0 1-& oat, OF THFILED-OFFICE RTARY 2011JAN21 AM10:23 CUMBERLAND CQUNTy PE?t""y! VAHIA ic) ceurtySuite Sherff_ T?leo ofE_ arc , VITELLS FARGO BANK, N.A., SB/M WELLS FARGO HOME MORTGAdE, INC. Plaintiff V. RUSSELL E. CLOUSER LISA M. CLOUSER Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO. 10-2577-CIVIL TERM CUMBERLAND COUNTY PHS # 235922 AFFIDAVIT PURSUANT TO RULE 3129.1 WELLS FARGO BANK, N.A., SB/M WELLS FARGO HOME MORTGAGE, INC., Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 11 COUNTRYSIDE COURT, CAMP HILL, PA 17011-1518. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot: be reasonably ascertained, please so indicate) RUSSELL E. CLOUSER LISA M. CLOUSER 2. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE 11 COUNTRYSIDE COURT CAMP HILL, PA 17011-1518 11 COUNTRYSIDE COURT CAMP HILL, PA 17011-1518 Address (if address cannot be reasonably ascertained, please so indicate) Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) Bank of America, N.A. (USA) Bank of America, N.A. (USA) C/o: Christopher E. Rice, Esquire Citibank (South Dakota), N.A. Citibank (South Dakota), N.A. C/o: Neil Burton, Esquire 4161 Piedmont Parkway Greensboro, NC 27410 10 East High Street Carlisle, PA 17013 701 East 60"' Street North Sioux Falls, SD 57104-0432 1060 Andrew Drive; Suite 170 West Chester, PA 19380 Commerce Bank, N.A. C/o: Eric M. Berman, Esquire Commerce Bank, N.A. C/o: Robert M. Kline, Esquire 500 West Main Street Babylon, NY 11702 500 North Gulph Road; #350 King of Prussia, P, 19406-2616 Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of ev6fy other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County 11 COUNTRYSIDE COURT CAMP HILL, PA 17011-1518 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for the Middle District of PA P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unworn falsification to authorities. August 13, 2010 By: i Atto ey for Plaintiff Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 F 44 WELLS FARGO BANK, N.A., SB/M WELLS FARGO HOME MORTGAGE, INC. : NO. 10-2577-CIVIL TERM VS. , CUMBERLAND COUNTY RUSSELL E. CLOUSER LISA M. CLOUSER Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: RUSSELL E. CLOUSER 11 COUNTRYSIDE COURT CAMP HILL, PA 17011-1518 LISA M. CLOUSER 11 COUNTRYSIDE COURT CAMP HILL, PA 17011-1518 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 11 COUNTRYSIDE COURT, CAMP HILL, PA 17011-1518 is scheduled to be sold at the Sheriffs Sale on 12/08/2010 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $117,299.52 obtained by WELLS FARGO BANK, N.A., SB/M WELLS FARGO HOME MORTGAGE, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. : COURT OF COMMON PLEAS : CIVIL DIVISION Plaintiff . I. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. r 2. You may be able Nopetition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 10 !.. SHORT DESCRIPTION By virtue of a Writ of Execution NO. 10-2577-CIVIL TERM WELLS FARGO BANK, N.A., SB/M WELLS FARGO HOME MORTGAGE, INC. vs. RUSSELL E. CLOUSER LISA M. CLOUSER owner(s) of property situate in HAMPDEN TOWNSHIP, Cumberland County, Pennsylvania, being (Municipality) 11 COUNTRYSIDE COURT, CAMP HILL, PA 17011-1518 Parcel No. 10-19-1596-092 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $117,299.52 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 A LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate, lying and being in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the westerly right-of-way line of Countryside Court, a 50.00 foot wide right-of- way, which said point is more particularly located at the intersection of the westerly right-of-way line of Countryside Court and the dividing line between Lots Nos. 98 and 99 on the Plan of Lots known as 'Countryside, Section (B); thence, from said point of beginning along the dividing line between Lots Nos. 98 and 99, South 81 degrees 16 minutes 00 seconds West, a distance of 118.00 feet to a point on the dividing line between Lots Nos. 97 and 99 on the aforesaid Plan of Lots; thence, from said point along the dividing line between Lots Nos. 97 and 98 and 99, North 08 degrees 44 minutes 00 seconds West, a distance of 85.00 feet to a point on the dividing line between Lots Nos. 99 and 100 on the aforesaid Plan of Lots; thence, from said point along the dividing line between Lots Nos. 99 and 100, North 81 degrees 16 minutes 00 seconds East, a distance of 118.00 feet to a point on the westerly right-of-way line of Countryside Court, South 08 degrees 44 minutes 00 seconds East, a distance of 85.00 feet to a point, the point and place of BEGINNING. BEING Lot No. 99 on the Plan of Lots known as Countryside, Section (B) prepared by Charles W. Junkins, Registered Surveyor, dated August 22, 1978 and recorded in the Office of the Recorder of Deeds of Cumberland County on April 11, 1974 in Plan Book 25, Page 7. HAVING THEREON ERECTED a dwelling house known and numbered as premises 11 Countryside Court, Camp Hill, Pennsylvania. TITLE TO SAID PREMISES IS VESTED IN Russell E. Clouser and Lisa M. Clouser, his wife, by Deed from Richard K. Gumbert and Patti J. Gumbert, his wife, dated 05/26/1994, recorded 05/27/1994 in Book 106, Page 125. PREMISES BEING: 11 COUNTRYSIDE COURT, CAMP HILL, PA 17011-1518 PARCEL NO. 10-19-1596-092 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) N010-2577 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A. Plaintiff (s) From RUSSELL E. CLOUSER AND LISA M. CLOUSER (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$117,299.52 L.L.$.50 Interest FROM 04/19/2010 TO DATE OF SALE ($19.28 PER DIEM) - $4,511.52 Atty's Comm % Due Prothy $2.00 Atty Paid $190.00 Other Costs Plaintiff Paid Date: AUGUST 19, 2010 (Seal) Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP, 1617 JFK BOULEVARD, SUITE 1400, ONE PENN CENTER PLAZA, PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 62205 On September 22, 20 10 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA, Known and numbered as, 11 Countryside Court, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 22, 2010 B Estate Coordinator j .: 14 - The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE z4f Patr1*0t'WXfW5 Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 2010-2577 Civil Term Wells Fargo Bank, NA, S/B/M to Wells Fargo Bank Home Mortgage, Inc Vs Russell E. Clouser Lisa M. Clouser Atty: Daniel G Schmleg By virtue of a Writ of Execution NO. 10-2577-CML TERM WELLS FARGb BANK, N.A., SB/M WELLS FARGO HOME-MORTGAGE, INC. vs. RUSSELL E. CLOUSER LISA M. CLOUSER owner(s) of property situate. in HAMPDEN TOWNSHIP, Cumberland Countv, Pennsylvania, being (Municipality) Il COUNTRYSIDE COURT, CAMP HILL, PA 17011-1518 Parcel No. 10-19-1596-092 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $117,299.52 Sworn tQ_4 subscribed before this. Id day November, 2010 A.D. r ; Notary Public COMMONWf:ALTH OF PENNSYLVANIA Notar181 Seal --i Sherrie L. K wW1 Notarif public Lower Paxton 'WP. Dauphin County _ My commission Expires Nov. 26, 2011 P?emb nnsvivania Association of NotarleS 10/15/10 10/22/10 10/29/10 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 22, October 29, and November 5, 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. r isa Marie Coyn , Editor SWORN TO AND SUBSCRIBED before me this 5 day of November, 2010 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH. CUMBERLAND COUNTY My Commission Expires Apr 28.2014 CUMBERLAND LAW JOURNAL Writ No. 2010-2577 Ctvil Wells Fargo Bank, NA, S/B/M to Wells Fargo Bank Home Mortgage, Inc. VS. Russell E. Clouser Lisa M. Clouser Atty.: Daniel G. Schmieg By virtue of a Writ of Execution NO. 10-2577-CIVIL TERM, WELLS FARGO BANK, N.A., S/B/M WELLS FARGO HOME MORTGAGE, INC. vs. RUSSELL E. CLOUSER, LISA M. CLOUSER, owners of property situate in HAMPDEN TOWNSHIP, Cumber- land County, Pennsylvania, being 11 COUNTRYSIDE COURT, CAMP HILL, PA 17011-1518. Parcel No. 10-19-1596-092. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $117,299- .52. 23